Operations & Maintenance Enforcement Guidance Part 192 Subparts L and M

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Enforcement Guidance

O&M Part 192

Revision Date


Code Section


Section Title

Procedural Manual for Operations, Maintenance, and Emergencies - Maintenance and Normal Operations

Existing Code Language

(b) Maintenance and normal operations. The manual required by paragraph (a) of this section must include procedures for the following, if applicable, to provide safety during maintenance and operations.

(1) Operating, maintaining, and repairing the pipeline in accordance with each of the requirements of this subpart and Subpart M of this part.

(2) Controlling corrosion in accordance with the operations and maintenance requirements of Subpart I of this part.

(3) Making construction records, maps, and operating history available to appropriate operating personnel.

(4) Gathering of data needed for reporting incidents under Part 191 of this chapter in a timely and effective manner.

(5) Starting up and shutting down any part of the pipeline in a manner designed to assure operation within the MAOP limits prescribed by this part, plus the build-up allowed for operation of pressure-limiting and control devices.

(6) Maintaining compressor stations, including provisions for isolating units or sections of pipe and for purging before returning to service.

(7) Starting, operating and shutting down gas compressor units.

(8) Periodically reviewing the work done by operator personnel to determine the effectiveness and adequacy of the procedures used in normal operation and maintenance and modifying the procedure when deficiencies are found.

(9) Taking adequate precautions in excavated trenches to protect personnel from the hazards of unsafe accumulations of vapor or gas, and making available when needed at the excavation, emergency rescue equipment, including a breathing apparatus and, a rescue harness and line.

(10) Systematic and routine testing and inspection of pipe-type or bottle-type holders including -

(i) Provision for detecting external corrosion before the strength of the container has been impaired;

(ii) Periodic sampling and testing of gas in storage to determine the dew point of vapors contained in the stored gas which, if condensed, might cause internal corrosion or interfere with the safe operation of the storage plant; and,

(iii) Periodic inspection and testing of pressure limiting equipment to determine that it is in safe operating condition and has adequate capacity.

(11) Responding promptly to a report of a gas odor inside or near a building, unless the operator's emergency procedures under §192.615(a)(3) specifically apply to these reports.

(12) Implementing the applicable control room management procedures required by §192.631.

Origin of Code

Original Code Document, 35 FR 13248, 08-19-1970

Last Amendment

Amdt. 192-112, 74 FR 63310, 12-03-2009

Interpretation Summaries

Interpretation: PI-94-034 Date: 10-24-1994
Operators must include in their manuals as much design and construction information, such as welding or other joining procedures, as is necessary to carry out operation, maintenance, and emergency response activities. For example, if a pipeline is to be repaired by replacing a segment of pipe, the operator's O&M manual would have to have design and construction information appropriate for that type of repair. Also, the O&M manual must contain procedures that enable operating and maintenance personnel to obtain as much original design and construction information as they need to carry out their assignments. However, such original information may be maintained apart from the manual.

Advisory Bulletin/Alert Notice Summaries

Advisory Bulletin ADB-10-06, Personal Electronic Device (PED) Related Distractions.

As with other modes of transportation, PHMSA recognizes the use of PEDs by pipeline employees who are performing operations and maintenance activities may increase safety risks if those individuals become distracted. In furtherance of the Department's effort to end the dangerous practice of distractions caused by PEDs throughout the various modes of transportation, PHMSA is issuing this Advisory Bulletin about the potential for distractions affecting pipeline safety.

PHMSA reminds owners and operators of natural gas and hazardous liquid pipeline facilities that there may be increased risks associated with the use of PEDs by individuals performing activities that affect pipeline operation or integrity. Pipeline operations and maintenance tasks require a critical level of attention and skill, which may be compromised by visual, manual, and cognitive distractions caused by the use of PEDs. Such distractions may also hinder their prompt recognition and reaction to abnormal operating conditions and emergencies.

Owners and operators of natural gas and hazardous liquid pipeline facilities should integrate into their written procedures for operations and maintenance appropriate controls regarding the personal use of PEDs by individuals performing pipeline tasks that may affect the operation or integrity of a pipeline. PHMSA is not discouraging the use of PEDs as a part of normal business operations. Owners and operators should also provide guidance and training for all personnel about the risks associated with the use of PEDs while driving and while performing activities on behalf of the company if that use poses a risk to safety.

Advisory Bulletin ADB-02-03, Gas and Hazardous Liquid Pipeline Mapping.

This bulletin is issued to gas distribution, gas transmission, and hazardous liquid pipeline systems. Owners and operators should review their information and mapping systems to ensure that the operator has clear, accurate, and useable information on the location and characteristics of all pipes, valves, regulators, and other pipeline elements for use in emergency response, pipe location and marking, and pre-construction planning. This includes ensuring that construction records, maps, and operating history are readily available to appropriate operating, maintenance, and emergency response personnel.

Advisory Bulletin ADB-00-02, Internal Corrosion in Gas Transmission Pipelines.

This bulletin is issued to owners and operators of natural gas transmission pipeline systems to advise them to review their internal corrosion monitoring programs and operations. Operators should consider factors that influence the formation of internal corrosion, including gas quality and operating parameters. Operators should give special attention to pipeline alignment features that may contribute to internal corrosion by allowing condensates to settle out of the gas stream.

Other Reference Material & Source

GPTC Guide Material is available.

Guidance Information

  1. The operator must have written procedures addressing each requirement of §192.605.

  2. An operator’s operations and maintenance procedures manual may vary in length and complexity depending on the specific equipment in service, the variety of facilities, the locations, and referenced versus incorporated material. The procedures must be detailed to clearly describe the manner in which each requirement will be met.

  3. The structure of the operations and maintenance procedures manual is not prescribed and may consist of a single comprehensive manual or multiple cross-reference volumes with referenced documents. The manuals can be made available to operations personnel as hard-copy or computer based documents but must be accessible at locations where operations and maintenance activities are conducted. If the operations and procedures manual(s) are computer based, the operator must provide a means to access the procedures in the event of computer failure.

  4. Procedures that are unique to a particular facility must be accessible at that facility.

  5. In addition to operations and maintenance functions performed by field personnel, tasks performed by operations control, engineering, integrity management and other functions associated with an office facility require written procedures that must be included in the operations and maintenance manual.

  6. The operations and maintenance procedures must be specific to address the facilities and equipment being used by the operator. The regulations define the minimum requirements but an operator’s procedures may need to exceed these basic requirements to ensure safe operation of the pipeline system. The operator’s written operation and maintenance procedures are enforced as a regulation.

  7. The procedures should be clear, straightforward and applicable to the company’s system.

  8. The operator must review and update, if necessary, the operations and maintenance procedures at least once each calendar year not to exceed 15 months. The operator must show that normal operations, abnormal operations, incidents, and emergency conditions were reviewed to determine if procedures modifications are needed. The individual procedures documents should include management approvals, origin date, and the effective date of the last revision.

  9. More specific than the requirements addressed in §192.605(a), as noted above.

  10. Personnel conducting pipeline operations need direct access (either on paper or electronically) to procedures, without delay when emergencies arise.

  11. §192.605(b) (8) is directed to procedures refinement, not employee evaluation.

  12. The operator must show that some analysis has been performed to determine the adequacy of a procedure and, if found to be inadequate, made appropriate modifications. The analysis may include incident data, near miss data, meetings to discuss the procedures, job safety analysis, etc., and should include documentation showing the analysis, discussions, etc., that determined the procedure was adequate or inadequate. A tie to the management of change management process should show the procedure modification that was made in response to the analysis.

  13. Observation of operator qualification training, where an operation or maintenance task is performed, is not by itself adequate to satisfy the requirements of §192.605(b)(8).

  14. Refinement and efficiency of procedures must not compromise safety.

  15. It is acceptable for operators to use the manufacturer’s recommended maintenance practices for compressor station maintenance (engine books, maintenance bulletins, etc.) regarding the applicable equipment at each location. If used, documents must be available at the work location (manuals at the office responsible for the work is acceptable).

  16. It is acceptable to post the specific start-up and shut-down instructions for each compressor unit at or near the local control panel used for operating the equipment; and have generic guidance procedures in its O&M Plan.

  17. Isolation and ESD procedures must be specific for each location.

  18. Properly structured procedure manuals will allow personnel to easily find specific O&M procedures.

  19. Operators must be able to provide a list of manuals that represent the entire set of required procedures.

  20. With regard to the potential overlap with OSHA rules, Section 4(b) (1) of the OSHA Act prohibits OSHA from exercising authority over working conditions when another agency exercises authority through regulation.

  21. The OPS procedures required to protect employees from vapors in excavations is different than OSHA confined space procedures.

  1. Final Order Guidance:

  1. El Paso Corporation [5-2008-1005] (November 23, 2009): 49 C.F.R. §192.605(b)(3) requires that an operator make available “construction records, maps, and operating history . . .to appropriate operating personnel.” In order to achieve compliance, operators must make this information “ready for use; at hand; and accessible (PHMSA Advisory Bulletin ADB-02-03).” In situations where personnel have to travel several miles to retrieve accurate or thorough information, “meaningful compliance with the regulatory requirement” has not been achieved. CO/CP

Examples of a Probable Violation

  1. The operator does not have a procedure that covers the tasks being performed.

  2. The operator fails to follow the written procedures.

  3. The written procedures have not been reviewed and/or updated within the required intervals.

  4. The operator has employed new equipment or technologies without having the appropriate procedures.

  5. The operator’s procedures for taking adequate precautions in excavated trenches do not include the use of appropriate instruments to test the atmosphere in the trench.

  6. The only procedures for addressing vapors in excavated trenches are OSHA’s confined space procedures.

Examples of Evidence

  1. Copies of the written procedures in question.

  2. Copies of the operators required records indicating that the procedures were not followed.

  3. A written record of the observed actions that violated the procedures.

  4. Photographs showing the probable violation.

  5. Written documentation of conversations with the operator’s personnel who are charged with establishing and following the plan.

  6. The operator’s internal incident investigation documents and PHMSA 7100.2 incident reports.

Other Special Notations

  1. If inadequacies are found with the written procedures the inspector should prepare a Notice of Amendment.

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